Wendy Wolkenstein and Rebecca Knepp v. Dan Heinrich and Samual Tillery
D. Nevada · Apr 6, 2026
- Jurisdiction
- federal
- Court
- D. Nevada
- Record ID
- wendy-wolkenstein-and-rebecca-knepp-v-dan-heinrich-and-samual-tillery-2026-04-06
- Observed outcome
- The court granted the motion for default judgment in part regarding damages but issued a formal warning regarding the use of AI-generated fake citations.
- Known monetary consequence
- Not recorded
Why this matter warrants attention
The court issued a formal warning to pro se plaintiffs for citing fabricated and misrepresented case law in a motion for default judgment. The judge attributed these errors to the use of generative AI and reminded the plaintiffs of their Rule 11(b)(2) duty to verify all legal authorities before filing.
The court reasoned that under Fed. R. Civ. P. 11(b)(2), all litigants, including pro se parties, have an affirmative duty to investigate and verify the veracity of legal citations. The court noted that generative AI often invents fake cases and that using such tools does not excuse a failure to verify, as chasing fake authority wastes judicial resources.
This case reinforces that pro se litigants are subject to Rule 11 verification requirements and that courts will actively monitor and warn against the use of generative AI to produce fabricated legal authority in court filings.
Failure modes and consequences
- Hallucinated_case_law
- Misrepresented_legal_authority
- Pro Se
- Fake Citations
- Misrepresented Authority
- Contract
- AI attribution
- Explicitly Recorded
- Recorded tool
- Generative AI (unspecified)
- Known monetary consequence
- Not recorded
- Procedural posture
- Order granting in part a motion for default judgment following the identification of AI-generated fake citations.
Damien Charlotin case archive
Publisher document archive. The recorded document is hosted in the upstream publisher archive.
Open underlying sourceA recorded source link is not a substitute for checking the underlying order, filing, opinion, or disciplinary record.
What this record does—and does not—establish
The court stated plaintiffs used artificial intelligence to prepare the motion.
The record summarizes the outcome described in the linked public source. The recorded document is hosted in the upstream publisher archive. This page is not a substitute for the complete docket, subsequent history, or jurisdiction-specific advice.
Latest evidence review: Primary Document Verified (high confidence).
Controls suggested by the public record
- Verify the existence, citation, court, and precedential status of every authority before filing.
- Confirm that each authority supports the stated proposition and has not been mischaracterized.
- Apply the same source-checking controls to AI (implied, unspecified) output as to any other research input.
- Read the linked source and subsequent docket history before relying on this record for legal work.